Privacy Notice

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This Privacy Notice was last updated: 16 December 2024

This Privacy Notice describes how Robert Half Japan Ltd ("we", “us”, “our” or “Robert Half”) may use, store and disclose or handle in any way Personal Information that we may collect about individuals.

We may modify this Privacy Notice from time to time. If we do, we will post the updated Privacy Notice on our website www.roberthalf.com/jp/en (the “website”).

This Privacy Notice should be read in conjunction with any privacy or collection statement we provide to you.

In this Privacy Notice, "Personal Information" refers to an information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information is true or not or is recorded in a material form or not. Please note that we might aggregate Personal Information from different sources (website, offline event). As part of this, we combine Personal Information that were originally collected by our international group of companies operating globally.

We will collect your Personal Information directly from you and from other sources including when you apply for a job via a job board, directly through our website, from Social Media sites such as LinkedIn, Facebook and X or when you provide us with your details during a job fair, promotional, networking or training event. We will use your Personal Information to provide you with work finding services.

When you ask us to provide you with work finding services, we will ask you to register as a Candidate. During our Candidate Registration process, we will collect your Personal Information directly from you, your CV, from employment referees and via online tests you may perform at our request.

We may disclose your Personal Information to our clients for relevant job vacancies with your consent. Our clients may request additional Personal Information about you in relation to their job vacancies and requirements to assess your suitability for the position.

Your Personal Information will be securely stored in our systems.

The categories of Personal Information we may collect include:

your identity (your full name, previous names, evidence of change of name, gender, and date of birth).

evidence of your right to work in Japan which may include a photograph, nationality, place of birth, birth certificate, driving licence, etc (in accordance with the Department of Home Affairs requirements);

contact details including your email, home address and phone numbers so that we can contact you by email and text message or deliver equipment necessary for your employment with us;

bank account and Japan My Number Card number (so we can make payments to you and account for tax if you are working as a temporary worker supplied through Robert Half).

pension details, dependents (if you are working as a temporary worker supplied through Robert Half).

your job search criteria, preferences and expectations.

your qualifications, skills, experience and training.

current and desired remuneration/payrate and other benefits.

educational history.

employment history.

references.

other information that you, your referees or our clients provide to us, including personal feedback and notes of our interactions with you and/or others in relation to your suitability for work with us or through us.

aptitude assessment results.

the results of background checks.

Medical certificates for human resources (HR) management, if you are working as a temporary worker supplied through Robert Half.

other information contained in your CV or that you choose to provide to us.

technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. For the purposes stated in “How we use your Personal Information”, we may combine this technical data with your Personal Information, and the Informative Data defined in the “Cookies and Informative Data” section below held by us or our group companies. We may also receive technical data about you if you visit other websites employing our cookies. Please see the ‘Cookie’ section below for further details

profile data including your username and password, your interests, preferences, feedback and customer survey responses.

usage data including information about how you use our website and services.

marketing and communications data including your marketing and communication preferences.

To provide you with work finding services we will send you job alert emails matching your job search criteria and preferences. From time to time you may also receive job alerts or event invitations which we consider you may find interesting.

You can stop receiving these job alerts or event invitations at any time by clicking on the unsubscribe link contained in the email.

If you are applying for a role as our employee, we will collect Personal Information from you via your CV, referees, professional and educational organisations and other sources. We will process your Personal Information for the purposes of administering the application, managing the internal hiring process and assessing your suitability. We will store your Personal Information securely in our confidential online HR database. Your Personal Information cannot be viewed or accessed by anyone except for members of HR and Talent Acquisition in Japan, Australia and the US and other staff if they are connected to the hiring process, such as interviewing, assessing your suitability for the role you have applied for and communicating with you. Except for the above, we do not share our HR database with any group companies, and we will take steps to ensure that your Personal Information is adequately protected, secure and kept confidential. If we engage a third party to provide pre-employment screening services or testing, we will ensure that access is limited to the Personal Information that is compatible with those services and the service provider is contractually obliged to comply with applicable data privacy laws, confidentiality and provide adequate safeguards to keep your Personal Information secure until it is deleted.

By applying for employment with us, you consent to us processing your Personal Information for these purposes. You have the right to withdraw your consent at any time. If you withdraw your consent, we will not be able to continue with your application.If your employment application is unsuccessful, we will retain your Personal Information on our HR database for a reasonable period for the purposes of evidencing that we have conducted the recruitment process in a fair and transparent way and have not discriminated against applicants on prohibited grounds. At the end of the retention period, your Personal Information will be deleted. Occasionally we may ask if you would like us to retain your CV data if we consider that you may be suitable for future roles. We will only do this with your consent.

We will only collect sensitive personal information (such as medical certificates for HR management if you are working as a temporary worker supplied through Robert Half) with your consent. This information will be retained for no longer than necessary before being deleted.

If you are a client or supplier or a potential client or supplier, of goods and services we will collect and process information about individuals in your organisation. We may enter the individual’s name, contact number, and business email address into our database as a designated corporate point of contact for that organisation, together with the individual’s other business contact data. Usually, this is only Personal Information processed for the purposes of contacting the organisation in relation to our services and authorising time sheets or the supplier as a recipient of the supplier’s goods and services. If the individual corporate point of contact is also a registered candidate, we may be processing additional Personal Information for work finding and other purposes as described in this Privacy Notice.

The source of a corporate point of contact may be the individual themselves, or their name and business details may be provided to us by a member of their HR or Procurement department or another hiring manager or existing business contact or a candidate we have placed at the organisation. We may also obtain these details from websites, social media and other sources. We may send business to business email marketing to corporate points of contact. An individual corporate point of contact can ask us at any time to stop sending business marketing emails to their business email address by filling out our online Unsubscribe form: Newsletter Unsubscribe | Robert Half.

If you are a referee, we collect information that is reasonably necessary for us to determine a candidate’s suitability for work with us or through us. The main types of information we collect about referees are:

your contact details including your email address and telephone numbers;

details of your job title/description; and

your confidential opinions about a candidate and their suitability for work with or through us.

When you use this website, we may ask for certain Personal Information including your name and contact information (email, home address and phone number). Depending on the nature of your enquiry or activities on our website, we may also ask for your job search criteria and preferences, employment experience, salary, and other background information together with any login ID and password (if any) created by you. You can sign up to send you job alerts through the website by completing your job search criteria and preferences. You can stop receiving these job alerts at any time by clicking on the unsubscribe link contained in the job alert email.

If you do not provide such information, we may not be able to provide you with access to certain services and functionality of the website or with any other services you request.

Our website also utilises cookies to track your online activities, including, but not limited to, registration, submissions, and information requests. Cookies are pieces of information that a website transfers to your computer's hard disk for record keeping purposes. Most web browsers are set to accept cookies. Cookies in and of themselves do not personally identify users, although they do identify a user's browser. If you do not wish to receive any cookies, you may set your browser to refuse cookies. This may mean you will not be able to take full advantage of the services on the Site. Please see our Cookies Notice for further information about the cookies we use.

We may automatically collect or receive from third parties the following data (“Informative Data”) through tracking tools such as cookies, web beacons, or tracking pixels to provide you with information or advertisements tailored to your interests and preferences. We may use this Informative Data either independently or in combination with other personal information.

Informative Data includes:

data that cannot independently identify a specific individual, includes behavioral history (data used to analyse interests and preferences by aggregating data such as website browsing history), email tracking information, and advertising identifier information.

We will only use your Personal Information for the purposes for which we collected it, and will not use or disclose any information about you without your consent, unless the use or disclosure is:

for the purpose of disclosing information to companies and individuals we employ to perform business functions and services on our behalf, on the basis that such companies and individuals must protect your Personal Information and may not disclose or use it for unrelated purposes. Such functions may include, for example, hosting our Web servers, analysing data, providing legal, accounting and marketing services;

permitted under the Act on the Protection of Personal Information;

necessary to provide you with a product or service which you have requested;

to the extent necessary or appropriate to government agencies, advisors, and other third parties in order to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to (a) comply with the law requiring such disclosure; (b) protect the rights or property of Robert Half or its affiliated companies; (c) prevent a crime or protect national security (d) protect the personal safety of the users or the public; (e) to assist the investigation of an offence by a law enforcement authority; or (f) prevent a serious or imminent threat to an individual's life, health or safety or public health or safety; or

as part of an automated solution to assess your suitability as a candidate for particular roles and for the purpose of considering your suitability for other, similar roles.

Please note that when the purpose of use is separately limited by laws and regulations, such as the use of individual numbers under the act on the use of numbers to identify a specific individual in administrative procedures (so-called My Number Act), we will not use it for any purpose other than the permissible purpose of use under the relevant laws and regulations.

In addition to the purposes set forth in Your Personal Information and How We Collect It, we may process your Personal Information for other legitimate business purposes such as targeting advertisements, producing statistics, analysing how successful our marketing campaigns or services are, optimizing our advertisement distribution, analysing the number of visitors to our website, performance on our website and complying with other contractual, legal and regulatory obligations and duties.

If you provide us with information about third parties, we will assume that the third party in question has given you permission to do so and to Robert Half collecting, processing and disclosing their Personal Information to the same extent as yours.

Our success is dependent on efficiently matching candidates to clients’ vacancies. In this context we use artificial intelligence (AI) provided by a third party based in the European Union as this assists our recruitment consultants perform the search and match of proposed candidates with client job vacancies more efficiently. The benefit of the AI search capability is that it supports our recruitment consultants to search more CVs and match Personal Information against clients’ job vacancies faster, ignoring irrelevant data. Our recruitment consultants are presented with a list of proposed candidates that are potentially suitable for a client’s vacancy, but it does not lead to automated decision-making. Our recruitment consultants decide which candidates to shortlist for a specific client’s job, based on their expertise, knowledge of the job market, insight into the client’s business and requirements for the role, candidate discussions and other relevant criteria. Clients’ (through their hiring personnel) decide which candidates to select for interview (if any). Our clients’ hiring personnel (not our AI tool) make the final decision on which candidate to select for their job (if any) and ultimately to proceed to hire/engage/employ the candidate.

If you object to the processing of your Personal Information by our AI tool, our recruitment consultants will continue to provide work finding services using other methods to search for job opportunities for you. The Personal Information of candidates who are no longer available for work, not actively seeking a job, have recently commenced permanent employment or who object the processing of their Personal Information by AI, will be deleted by our AI service provider.

To the extent necessary or appropriate and without notifying you, Robert Half may disclose your Personal Information to external third parties (who are not members of the Robert Half group of companies) in the following circumstances:

to third parties in and outside Japan we employ to perform business functions and services on our behalf. Examples of service providers include: right to work checks, providing payroll services to enable us to pay our employees and temporary workers who work on client premises; background screening and verification services; data storage facilities including in the US and the Cloud; hosting our Web servers; managing job posting applications via our third-party provider; analysing data and producing statistics and legal, accounting, audit and other professional services.

If engaged through the Robert Half, processing of pay and other benefits related to your engagement may be processed by third parties in and outside Japan.

to government agencies if required by applicable laws or regulations.

to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to: (a) comply with the law requiring such disclosure; (b) protect the rights or property of Robert Half or its group companies and it is difficult to obtain your consents in advance; (c) prevent a crime, protect national security or for fraud detection or prevention and it is difficult to obtain your consents in advance; or (d) protect the personal safety of individuals using our website or members of the public and it is difficult to obtain your consents in advance.

to third parties in and outside Japan to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them; and

to third-party IT consultants carrying out testing and development work on our IT systems, other service providers (including providers of relevant IT solutions) who we may appoint as data processors and who may be based outside of Japan where your data may be stored.

Where applicable, we will impose appropriate contractual, security, confidentiality and other obligations on to third party service providers and processors we have appointed, based on the nature of the services they provide to us. We will only permit them to process your Personal Information in accordance with the law and our instructions. We do not allow them to use your Personal information for their own purposes and when our relationship ends, we will ensure your Personal Information is securely returned or destroyed so that you can no longer be identified.

We may use your Personal Information to send you direct marketing communications or marketing materials regarding our products or services, including job vacancies and event invitations. You may opt out of receiving such marketing communications by unsubscribing from our database.

Robert Half is part of an international group of companies operating globally. We may share and jointly use some of your Personal Information or Informative Data with our group companies, including Protiviti LLC (Protiviti Goudou Kaisya) a Japan based consultancy, our parent company Robert Half Inc., based in the United States, and other group companies outside Japan, who may use and process your Personal Information or Informative Data to the extent necessary to achieve purposes as described in this Privacy Notice. We may also transfer your personal details to clients of the Company or third parties who provide services to the Company. These entities are located in Japan, Australia, United States, EEA and other countries.

The data protection laws outside Japan may not provide an equivalent level of protection to those in Japan and in these circumstances, we will take steps to ensure that your Personal Information is adequately protected, secure, kept confidential and that we have a lawful basis for the transfer.

Robert Half Japan Ltd, TOKYO TORCH Tokiwabashi Tower 24F, 2-6-4 Otemachi, Chiyoda-ku, Tokyo, 100-0004, Japan, Yewki Tomita will be responsible for the management of the jointly used Personal Information.

Robert Half will endeavour to take reasonable steps to protect Personal Information from misuse, interference, loss, unauthorised access, modification or disclosure. You should note that the internet is not a completely secure method of transmitting information and, as such, we are not responsible for the security of any information sent or received over the internet. Furthermore, Robert Half may disclose, and you consent to such disclosure of Personal Information to Robert Half servers and electronic systems located outside the country where you are located. This is due to Robert Half using overseas facilities to store, process or back up its information. However, this does not change our commitment to keep your information secure.

You are entitled to request access to any Personal Data defined in APPI that we hold about you and record of disclosure if any, and you can do this by contacting us via email: [email protected]. You may request that we correct Personal Data that is inaccurate or out of date, erase and cease processing your Personal Data and cease disclosing your Personal Data to third parties in accordance with the Act on the Protection of Personal Information (“APPI”), subject to limited exceptions set out in the APPI.

We may charge a reasonable fee to exercise any of these rights where permissible under applicable laws. Alternatively, we may refuse to comply with your request in these circumstances. If you have any concerns or complaints about how we handle your Personal Data , or if you have any questions about this Privacy Notice, please contact us by emailing [email protected].

In most cases we will ask that you put your request in writing to us. We will investigate your complaint and will provide our response within 30 days.

If we change material terms in this Privacy Notice, we will provide notice of the revised Privacy Notice for 30 days on the home page at www.roberthalf.com/ja/en with a link back to this Privacy Notice or we will ask you to consent to the updated Privacy Notice if requested by any applicable law. Provided the purpose for which we have collected the Personal Information has not significantly changed, the amended Privacy Notice will apply between us after the notice period has passed, regardless of whether or not we have given you specific notice of any change.

This Privacy Notice is effective as of 16 December, 2024. If you have any questions about this Privacy Notice, please contact us at:

Robert Half Japan Ltd TOKYO TORCH Tokiwabashi Tower 24F 2-6-4 Otemachi Chiyoda-ku, Tokyo 100-0004 Japan

Email: [email protected]